Holland v. Commissioner of Social Security
1:24-cv-01540
N.D. OhioApr 14, 2025Background
- Demetre A. Holland filed for supplemental security income (SSI) benefits alleging disability due to various physical and psychological impairments starting March 2020, including shoulder arthritis, spinal issues, anxiety, and asthma.
- Holland’s application was denied initially and on reconsideration; he subsequently requested a hearing before an Administrative Law Judge (ALJ), which was held in June 2023.
- The ALJ found Holland was not disabled, concluding that while he had severe physical impairments, his claimed limitations were not supported by the totality of the record and that he retained the residual functional capacity (RFC) to perform a limited range of light work.
- Holland appealed the ALJ’s decision to the Appeals Council, which denied review, making the ALJ’s decision the Commissioner’s final decision.
- Holland sought judicial review in federal court, asserting that the ALJ did not properly support the RFC determination and failed to comply with regulatory requirements regarding subjective symptom evaluation and medical opinion analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Substantial support for RFC | ALJ failed to identify substantial evidence for RFC, selectively cited evidence, and minimized severity of symptoms | ALJ considered all relevant evidence, did not have to cite every piece, and linked RFC to the record | ALJ’s RFC finding is supported by substantial evidence |
| Compliance with SSR 16-3p and subjective symptom evaluation | ALJ ignored/inadequately factored reasons for non-treatment (anxiety, marijuana use) and underplayed symptom impact | ALJ analyzed factors as required, discussed treatment reasons, and detailed daily activities | ALJ complied with SSR 16-3p and sufficiently evaluated subjective claims |
| Medical opinion analysis—Dr. Markovic’s check-box opinion | ALJ didn’t discuss support for treating provider’s limitations (used check-box, not detailed notes) | ALJ was not required to give controlling weight; check-box forms lacking rationale are properly discounted | ALJ reasonably discounted check-box opinions for lack of support |
| State agency reviewer opinions | ALJ did not explain support/consistency but included greater RFC restrictions than consultants opined | No reversible error as RFC was more restrictive (favorable) than consultants and ALJ explained basis | No error; any deficiency was harmless |
Key Cases Cited
- Jones v. Comm'r of Soc. Sec., 336 F.3d 469 (6th Cir. 2003) (substantial evidence supports ALJ’s decision if it falls within a "zone of choice")
- Bass v. McMahon, 499 F.3d 506 (6th Cir. 2007) (reviewing court cannot resolve evidentiary conflicts or question credibility findings)
- Key v. Callahan, 109 F.3d 270 (6th Cir. 1997) (ALJ decision withheld if supported by substantial evidence, even if evidence could support a contrary result)
- Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (burden of proof in SSA cases and sequential evaluation standards)